I still do not see any advantage to skipping over Texas, even Toyota went there. They are simply more business friendly, let alone by far the largest deployment of wind turbines in the US. While many associate it with oil Texas never really sat still, energy is energy.
My guess is because you can't even BUY a Tesla in Texas. Why would they set up a $5B factory in a state where they can't even sell a car? http://www.teslamotors.com/advocacy_texas
EDIT: Amongst other reasons of course, just a guess on one factor. Hard to say it's business friendly when they've banned the company from doing business there.